On February 8, 2012, the United States Internal Revenue Service ("IRS") and Department of the Treasury ("Treasury") issued long awaited proposed regulations under the so-called "FATCA" provisions in sections 1471 through 1474 of the Internal Revenue Code.

On March 29, 2011, the Internal Revenue Service issued Revenue Procedure 2011-26 (the "Revenue Procedure"), which provides guidance on the rules applicable to the 50-percent and 100-percent first-year depreciation deductions ("bonus depreciation") for qualified property that were added to the Internal Revenue Code of 1986, as amended (the "Code"), by the Small Business Jobs Act of 2010 (the "SBJA") and the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "Tax